The Denka Group is committed to building partnerships with all of its business partners to strengthen mutually-beneficial relationships, and fulfilling its social responsibilities throughout the supply chain to achieve sustainable development. To these ends, the Denka Group established the Denka Group Sustainable Procurement Basic Policy and the Denka Group Sustainable Procurement Guidelines based on the Denka Group ESG Basic Policy. To promote sustainability throughout the supply chain, this Policy and these Guidelines apply to transactions with all business partners.

Denka Group Sustainable Procurement Basic Policy

Article 1

The Denka Group respects internationally recognized standards and conducts procurement operations in accordance with applicable laws and regulations as well as corporate ethics.

Article 2

When procuring raw materials, equipment, and construction services, the Denka Group comprehensively takes into consideration quality, price, and delivery time as well as its business partners’ technical capabilities, supply stabilities, and measures its business partners take to address social issues including human rights problems and environmental preservation including climate change.

Article 3

The Denka Group sincerely treats its business partners as important partners in carrying out its business and strives to establish mutual understanding and build relationships of trust through fair transactions.

Article 4

The Denka Group respects human rights and does not engage in any discrimination on the basis of gender, age, nationality, ethnicity, race, origin, religion, belief, disability, sexual orientation, or gender identity. All child labors and forced labors are prohibited, and the Denka Group strives to improve workplace environments, safety, and health, and respects the freedom of association and right to collective bargaining of employees. Furthermore, the Denka Group complies with the minimum wage laws and regulations of each country and region where it conducts business and strives to conduct procurement with consideration for the payment of living wages.

Article 5

The Denka Group recognizes that consciousness for global environmental issues including climate change is an important matter and conducts procurement with consideration for curtailing environmental impact including reducing energy use, cutting greenhouse gas emissions, protecting water and biodiversity, conserving and recycling resources, and reducing waste.

Article 6

The Denka Group does not accept inappropriate entertainment or gifts that exceed social norms in its relationships with its business partners,. Furthermore, the Denka Group prepares for the actions of anti-social forces and organizations that pose threats to civil society or corporate activities, takes a firm stance towards such persons/organizations, and maintains no relationships with them.

Article 7

The Denka Group maintains the confidentiality of confidential information* of business partners acquired through procurement activities, and manages and protects the intellectual property rights of business partners in an appropriate way.

• *Confidential information generally refers to information disclosed through documents (including data recorded electronically or optically) that is agreed to be confidential as well as information disclosed orally with prior notification that it is confidential.

Article 8

The Denka Group provides fair and equitable opportunities for competition on equal terms to all of its business partners.

Established: September 2013
Revised: April 2025

Denka Group Sustainable Procurement Guidelines

These Guidelines were established to state matters that the Denka Group and its business partners should address together to fulfill their social responsibilities. The Denka Group requests that all suppliers understand and implement these Guidelines.

1. Respecting the Laws and Internationally Recognized Standards

Companies must respect internationally recognized standards in addition to complying with the laws and regulations of their home country as well as countries and regions where they conduct business.

2. Human Rights and Labor

Companies must respect the rights of workers in line with international human rights standards in addition to complying with relevant laws and regulations.

(2-1) Prohibiting Forced Labor

Companies must not use labor obtained by forced, bonded, exploitative prison labor, slavery, or human trafficking. Companies also must not force to work, and must keep the right of workers to terminate employment.

(2-2) Prohibiting Child Labor and Respecting the Rights of Young Workers

Companies must not allow children who are under the minimum age for employment. Furthermore, companies must also not allow young workers under the age of 18 to perform hazardous work that is likely to jeopardize their health or safety, including night work or overtime.

(2-3) Decent Working Hours

Companies must not allow workers to work exceeding the maximum working hours set by local laws and regulations, and appropriately manage working hours and days off in consideration of internationally recognized standards.

(2-4) Adequate Wages and Allowances

Companies must comply with all applicable laws and regulations regarding payments of work (including minimum wage, overtime payments, and allowances and deductions required by law). Furthermore, it is expected that companies pay wages at a level that allows workers to support their basic needs (a living wage).

(2-5) Prohibiting Inhumane Treatment

Companies must respect the human rights of workers and must not treat workers in a manner that is or may be construed inhumane, including physical and psychological abuse, coercion, or harassment.

(2-6) Prohibiting Discrimination

Companies must not engage in discrimination or harassment based on gender, age, nationality, ethnicity, race, place of origin, religion, belief, disability, sexual orientation, gender identity. Companies must also consider requests from workers regarding religious practices where appropriate.

(2-7) Freedom of Association and Right to Collective Bargaining

In conformance with local laws and regulations, companies shall respect the right to collective bargaining of workers and openly communicate with workers for improving working environments and wage conditions.

3. Health and Safety

In addition to complying with relevant laws and regulations, Companies must take consideration of standards such as ILO health and safety guidelines to minimize injury and illness in the workplace and maintain a safe and healthy working conditions.

(3-1) Occupational Safety

Companies must identify and assess risks regarding occupational safety and maintain safety through proper design, engineering and administrative controls.

(3-2) Emergency Preparedness

Companies must identify the possibility of emergency situations by such as natural disasters or accidents that may adversely affect human life or safety, establish procedures in case of emergency to minimize harm to workers and property, install the required equipment, and conduct training and drills so that the required responses can be taken in case of emergency.

(3-3) Occupational Injury and Illness

Companies must identify, assess, record, and report the status of occupational injury and illness, and implement appropriate countermeasures and corrective actions.

(3-4) Industrial Hygiene

Companies must identify, assess, and appropriately control the risk of workers being exposed to hazardous biological, chemical, or physical agents in the workplace.

(3-5) Physically Demanding Work

Companies must identify and assess worker exposure to the hazards of physically demanding tasks and appropriately control such work so that it does not lead to occupational injury and illness.

(3-6) Machine Safeguarding

Companies must evaluate the machinery used by workers for safety hazards and provide appropriate safeguarding.

(3-7) Health and Safety at Facilities

Companies must appropriately maintain the health and safety of facilities and accommodations provided to workers.

(3-8) Health and Safety Communication

Companies must provide training on appropriate health and safety information regarding various workplace hazards that workers are exposed to in the workplace in languages and methods that the workers can understand. A system that enables workers to provide feedback on safety is also required.

(3-9) Worker Health Management

Companies must conduct appropriate health management for all employees.

4. Environment

Companies must recognize that consciousness for the global environment is an important issue and actively address global environmental problems, such as climate change, resource depletion, and pollution, give consideration to the health and safety of people in its relevant local communities, and conduct procurement with consideration for curtailing environmental impact including cutting greenhouse gas emissions, protecting water and biodiversity, recycling resources, and reducing waste.

(4-1) Environmental Permits and Reports

Companies must obtain the permits and approvals required for conducting business as well as register and report according to local laws and regulations.

(4-2) Reducing Energy Consumption and Greenhouse Gas Emissions

Companies must address energy efficiency and make continuous efforts for reducing greenhouse gas emissions and energy consumption.

(4-3) Air Emissions

Companies must comply with relevant laws and regulations and implement appropriate measures for reducing the emission of hazardous substances to the atmosphere.

(4-4) Water Management

Companies must comply with laws and regulations, monitor the source, usage, and discharge of water used, and save water. All wastewater must be tested as required, and monitored, controlled, and processed before discharge or disposal. Sources of pollution that may cause water pollution must also be identified and appropriately managed.

(4-5) Effective Utilization of Resources and Waste Management

Companies must comply with laws and regulations and implement appropriate management in order to promote the 3Rs (reduce, reuse, and recycle), ensure the effective utilization of resources, and minimize waste.

(4-6) Chemical Substance Management

Companies must comply with laws and regulations and manage chemicals and other substances that pose hazard to humans or the environment to ensure safe handling, transport, storage, use, recycling or reuse, and disposal of such substances.

(4-7) Managing the Chemical Substances Contained in Products

Companies must comply with all laws, regulations, and customer requests applicable to the prohibition and restriction of specific substances contained in products.

5. Fair Trading and Ethics

Companies must respect internationally recognized standards, comply with applicable laws and regulations as well as corporate ethics, and conduct business activities based on high ethical standards.

(5-1) Preventing Corruption

Companies must not be involved in bribery, corruption, blackmail, or embezzlement in any form. Companies must also not provide or accept any promises, propositions, or approvals as a means of obtaining bribes or any other illicit or inappropriate benefit.

(5-2) Exclusion of Anti-social Forces

Companies must prepare for the actions of anti-social forces and organizations that pose threats to civil society or corporate activities, take a firm stance towards such persons/organizations, maintain no relationships with them, and provide no benefit to them.

(5-3) Fair Information Disclosure

Companies must disclose information regarding labor, health and safety, environmental activities, business activities, organizational structure, financial situation, and performance according to applicable laws and regulations and industry practices. Falsification of records or the disclosure of false information is not allowed.

(5-4) Respecting Intellectual Property

Companies must respect intellectual property rights and the transfer of technology and expertise must be performed in a manner where intellectual property is protected. Companies must also protect the intellectual property of third parties such as customers and suppliers.

(5-5) Conducting Fair Business

Companies must engage in fair business, competition, and advertising.
In doing so, companies must comply with laws and regulations relating to fair competition and transactions, comply with all applicable laws and regulations and other social norms in the course of the companies business activities, and conduct fair advertising in relation to products and services.

(5-6) Protecting Whistleblowers

Companies must protect the confidentiality of information regarding whistleblowing and the anonymity of whistleblowers, and avoid retaliations towards whistleblowers.

(5-7) Responsible Minerals Procurement

Companies must exercise due diligence to ensure that the minerals such as tantalum, tin, tungsten, and gold contained in its products manufactured do not cause or contribute to serious human rights abuses, environmental destruction, corruption, or disputes in Conflict-Affected and High-Risk Areas.

6. Quality and Safety

Companies must ensure the safety and quality and provide correct and accurate information on provided products and services.

(6-1) Ensuring Product Safety

Companies must fulfill their responsibility as a supplier by ensuring that products meet safety standards stipulated by national laws and conduct design, manufacturing, and sales to ensure adequate product safety.

(6-2) Quality Management

Companies must comply with their own quality standards and customer requirements in addition to all laws and regulations applicable to the quality of products and services.

(6-3) Providing Accurate Information on Products and Services

Companies must provide correct and accurate information on products and services that will not cause misunderstandings.

7. Information Security

Companies must prevent leaks of confidential information and personal information, and enhance information security.

(7-1) Defense from Cyber Attacks

Companies must implement protective measures against threats such as cyber attacks and conduct management to prevent damage to the company and others.

(7-2) Protecting Personal Information

Companies must comply with relevant laws and regulations and appropriately manage and protect all personal information of suppliers, customers, consumers, and employees.

(7-3) Preventing Leak of Confidential Information

Companies must appropriately manage and protect the confidential information not only of their own but also received including from customers and third parties.

8. Business Continuity Planning

Companies must make preparations to ensure that they can quickly resume business activities in order to fulfill their responsibility of supply in the event that the company or a business partner becomes a victim of such as a large-scale natural disaster.

(8-1) Developing and Preparing a Business Continuity Plan

Companies must identify and assess risks to business continuity, examine their impact on the business, and establish preparatory measures required in the medium to long term and a business continuity plan (BCP) that indicates the status of those initiatives.

(8-2) Improving Supply Chain Traceability

Companies must ascertain upstream information of procuring raw materials and fuels to the extent possible, anticipate potential risks relating to raw materials and fuels and the suppliers themselves, prepare for those risks, and share risk information with customers.

Established: September 2013
Revised: April 2025

These Guidelines were prepared by making reference to the JEITA Responsible Business Conduct Guidelines.

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